F e bruary 22, 2016 U.S. Department of Transportation Docket Management System 1200 New Jersey Ave, SE W

ashington, DC 2 0590
Attention: FAA Administrator Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations form 14 CFR Part 21; 14 CFR 45.23(b); 14 CFR 61.113 (a) & (b); 14 CFR 91.7 (a); 14 CFR 91.9 ( b) (2); 14 CFR 9 1

. 1 0 3 ; 14 CFR 91.109; 14 CFR 9 1.119; 14 CFR 91.121; 14 CFR 91.151 ( a); 14 CFR 91.203 (a) & (b); 14 CFR 9 1

. 2 1 5 ( a) & ( b ); 14 CFR 91.131 (d); 14 CFR 91.405 (a); 14 CFR 407 (a) (1); 14 CFR 409 (a) (2); 14 CFR 417 ( a) & (b) Dear Administrator, Pursuant to the Section 333 of the FAA Mode r nization and Reform Act of 2012 (The Reform Act) and 14 CFR Part 11, Revolution 6 Media, LLC . is the operator of Small Unmanned Aircraft Systems (sUAS) equipped to conduct aerial photography and video data collection , hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to allow commercial operations of its sUAS so lon g a s such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333. Exemption is requested for the following Unmanned Aircraft ("UA"): DJI F550, DJI Inspire 1, Freefly ALTA. As described in more detail below, the requested exemption would permit the operation of small, unmanned and relatively inexpensive sUAS under controlled conditions in the NAS that is both limited and predetermined. Approval of this exemption would thereby enhanc e safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “...establish requirements for the safe operations of such aircraft systems in the national airspace system.” Section 333 (c) of the Reform Act. Regulat ions from which the exemption is requested:
1 4 CFR Part 21 1 4 CFR 45.23 (b) 1 4 CFR 61.113 (a) & (b) 1 4 CFR 91.7 (a) 1 4 CFR 91.9 (b) (2) 1 4 CFR 91.103 1 4 CFR 91.109 1 4 CFR 91.119 1 4 CFR 91.121 1 4 CFR 91.151 (a) 1 4 CFR 91.203 (a) & (b) 1 4 CFR 91.215 (a) &( b) 1 4 CFR 91.131 (d) 1 4 CFR 91 405 (a) 1 4 CFR 407 (a) (1) 1 4 CF R 409 (a) (2) 1 4 C FR 417 (a) & (b)This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333 (a) through (c) of the Reform Act. This law directs the Sec ret ary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of sUASs do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following:

• The sUAS’s size, weight, speed, a nd operational capability;

• Operation of th e sUAS in close proximity to airports and populated areas

• Operation of the sUAS within visual line of sight (VLOS) of the Pilot/”Operator” Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may operate safely in the na tional air space system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system.” Id. §333(c). The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory au thority b y its terms includes exempting civil aircraft, as the term is de finedunder §40101 of the Act, that includes sUASs, from the requirement that all civil aircraft must have a current airworthiness ce rtificate.
The Administrator may grant an exemption from the requirement of a regulation prescribed under su bsection (a) or (b) of this section or any sections 44702

-- 44716 of this title if the Administrator finds the exemption in the public interest. 49 U.S.C §44701(f) See also 49 USC §44744(a); 49 USC §4470 4 l 14 CFR §91.203 (a) (1).

Revolution 6 Media, LLC sUASs are rotorcraft weighting 55 or fewer lbs. including payload. They operate under normal conditions at a speed of no more that 50 kts a nd have the capabili ty to hover, and move in the vertical and horizontal plan simultaneously. They will operate only in line of sight of the Pilot/”Operator” and will operate with the permission of the property owner or a representative. Such operations will insure that the sUAS will “not create a hazard to users of the national airspace system or the public” as per the Reform Act Section 333 (b).
Given the small size of the sUASs involved and the limited environment within which that will operate, t he applicant falls squarely

w ithin that zone of safety (an equivalent le vel of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of sUASs to commence immediately. Also due to the size of the sUASs and the limited areas in which the relevant sUASs will o perate, approval of the application p resents no national security issue. Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended; the s tr ong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety with allow ing sUASs for commercial aerial videography and photography operations, the grant of the requested exemptions is in the public interest. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without delay.AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The applicant proposes that the exemption requested herein apply to civil aircraft that have the c haracteristics and the y operate with the limitations listed herein. These limitations provide for at least a nd equivalent ore ven higher le vel of safety of operations under the current regulatory struct ure because the proposed operations are conducted on closed off property under the permission of the p roperty owner or property representative.

These limitations and conditions to which Revolution 6 Media, LLC agrees to be bound when conducting commercial operations under an FAA issued exemption include: 1

. The sUAS will weigh less than 55 lbs. 2

. F l i ghts will be operated within visual line of sight (VLOS) of a Pilot/”Operator” and/or observer. 3

. M axi mum total flight time for each operational flight will be 30 minutes. Flights will be terminated at 20% battery power reserve should that occur prior to the 30 minute limit. 4

. Flights will be operated at an altitude of no more than 500 feet AGL or, when phot o graphing a structure taller than 500 feet, the sUAS will not be operated more than 100’ above the highest p oint on t he s tr ucture. 5

. Minimum crew for each operation will consist of the sUAS Pilot/”Operator”, and the Visual O b server. 6

. sUAS Pilot/”Operator” will be Pilot in Command (PIC). If the Pilot/”Operator” deems another

“ P i l ot/”Operator” “ to be qualifiedwith the necessary skills to be the “Pilot/”Operator”, that person can also be designated as “Pilot/”Operator” “ provided they have a minimum of 40 hour s of flight time with the sUAS. 7

. Flights will be operated at a lateral distance of at lest 50 feet from any inhabited structures, b u ildings, vehicles, vessels, or people no t associated with the operation. 8

. A briefing will be conducted in regard to the planned sUAS operations prior to each flight activity. It will be mandatory that all personnel involved with the operational duties of the flight be present f or this b riefing. 9

. Pilot/”Operator” and observer will have been trained in operation of sUAS generally and received up -- - to -- - date information on the particular sUAS to be operated. 1 0

. The “Pilot/”Operator” “ will have at least a class 3 medical certificate. 1 1

. Observer and Pilot/”Operator” will at all times be able to communicate by voice, radio, and/or text. 1 2

. Written and/or oral permission from the relevant property holders or property representatives will be obtained. 1 3

. If the sUAS loses communications or loses its GPS signal, the sUAS w ill have the capability to
r e turn to a pre -- - determined location and land autonomously. 1 4

. The sUAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or emergencies.
1 4 CFR §91.109: Fl ight Instruction No person may operate a civil aircraft (except a manned free balloon) that is being used for flight i n st ruction unless t hat aircraft has fully functioning dual controls. sUAS and remotely piloted aircra ft, by their design do not have fully functional dual. Fli ght control is accomplished th rough t he use of a control box that communicates with the aircraft via radio communication. The FAA has approved exemptions for flight training without full functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos. 5778K & 9862A. The equivalent level of safety is provided by the fact the neither a pilot nor passengers wi ll be carried in the aircraft and by the size and speed of the aircraft.1 4 CFR §91.119: Minimum Safe Altitudes Section 91.119 established safe altitudes for operation of civil aircraft. Section 91.119 (d) allows that helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) of this section, p rovided each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA. As this exemption is for a sUAS that is a helicopter and the exemption requests authority to operate at altitudes up to 500 feet AGL, an exemption may be needed to allow such operations. As set forth herein, the sUAS will never operate higher that 500 AGL with the exception that in circumstances where the sUAS is used to survey or photograph a s tructure w

hose height exceeds 500 feet AGL, the sUAS will not be operated more than 100 feet above the highest point on t he structure.
The equivalent level of safety will be achieved given the size, weight, speed of the sUAS as well as the l ocation
w here it is operated. No flight will be taken without t he permission of the property owner. B ecause of the advance notice to the property owner and other pa rticipants in the activity, all affected individuals will be aware of the planned flight operations. Compared to flight operations with aircraft or r o torcr aft weighing far more than the maximum 55 lbs. proposed herein and the lack of flammable fuel, a ny risk associated with these operations is f ar less than those presently presented with conve n tional aircraft operating at or below 500 feet AGL. In addition, t he low

-- - altitude operations of the sUAS will ensure separation between the sUAS operations and the operations of conventional aircraft that must comply with Section 91.119.

1 4 CFR §91.121 Altimeter Settings This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” As the sUAS may not have a barometric altimeter, but instead a G P S al titude readout, and exemption may be needed. An equivalent level of safety will be achieved by the Pilot/”Operator”, pursuant to the safety checklist and live flight data monitoring, confirming the altitude o f the la u n c h s ite shown on the GPS altitude indicator before flight.
1 4 CFR §91.151(a): Fuel Requirements for Flight in VFR Conditions Sections 91.151(a) prohibits an individual from beginning “a flight in an airplane under VFR conditions u n l e ss (c o n sidering wind and forecast weather conditions” there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed – ( 1) D u ring the day, to fly after that for at least 30 minutes; or (2) at night, to fly after that for at least 45 minutes.”
The battery p owering the sUAS provides less than 30 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to approximately 10 minutes in length. Given the limitations of the sUAS’s proposed flight area and t he location of its proposed operations within a predetermined area, a longer timeframe for flight in daylight or twilight CFR c onditions is reasonable.
Applicant believes that an exemption from 14 CFR §91.151 (a) falls within the scope of prior exemptio n s. See Exemption 10673 (allowing L ockheedMartin Corporation to operate without compliance with FAR 9 1

. 1 5 1 ( a)). Operating the sUAS, in a limited area where only people and property owners or representative with less than 30 minutes of reserve fuel, does n ot engender the type of risk that Section 91.151 (a) was intended to alleviate given the size and speed of the sUAS. Additionally, limiting the sUAS flight to 10 minutes would greatly reduce the utility for which the exemption will be granted.Applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 2 0 % of b at tery power – whichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5 7 4 5 , 1 0673, and 10808. 14 CFR §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration
The regulation provides in the pertinent part: (a ) E xcept a provided in § 91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate. . . . (b) No person may operate a civ il aircraft u nless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit e n tr ance so that it i s l e gi b le to passengers or crew. The sUAS fully loaded weighs less that 55 lbs. and is operated without an onboard pilot. As such, there is no ability to place to carry certification and registration documents or to display them on the sUAS. An equivalent level of safety will be achieved by keeping these documents at the ground control point where the Pilot/”Operator” flying the sUAS will have immediate access to the documents to the extent they are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A r epresentative sam ple of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797 9797A, and 10700.
14 CFR §91.215 (a) and (b); 14 CFR §91.131 (d); ATC transponder and altitude reporting equipment and us e

The pertinent section of 91.215 (a) & (b) requires the “(a) All airspace: U.S.--

- registered civil aircraft. F or operations not conducted under part 121 or 135 of this chapter, ATC transponder equipment installed. . . ( b) All airspace. Unless otherwise authorized or directed by ATC, no person may operate an air craft in the airspace described in p ar agraphs (b)(1) through (b)(5) of this sec tion, unless that aircraft is equipped with an operable coded radar b eacon transponder”. . . This requirement applies (1) All aircraft. In Class A, Class B, and Class C airspace a re as ; (2) All aircraft. In all airspace within 30 nautical miles of an airport listed in appendix D, section 1 of this part from the surface upward to 10,000 feet MSL; Likewise, the pertinent section of 91.131 (d); Operating Rule in Class B Airspace (d) o ther equipment requirements. “No person may operate an aircraft in a Class B airspace area unless the aircraft is equipped with (1) The applicable operating transponder and automatic altitude reporting equipment specified in § 91.215 (a) . . . and (2) After January 1, 2020 , the applicable Automatic Dependent Surveillance--

- Broadcast Out equipment specified in §91.225.”Because of the small size and limited lifting capacity of the sUAS, the sUAS cannot be fitted with and operate a transponder and automatic altitude reporting equipment specified in paragraph of 91.215 (a) and (b) and 91.131 (d). An exemption from these requirements is requested. The equivalent l evel of safety can b e assured using the p rocedures defined for each class of airspace.
Within the surface areas of Class “B”, Class “C”, Class “D” airspace Within the lateral boundaries of the airspace, the Pilot/”Operator” “ will establish 2 way communications with the ATC facility having jurisdiction for that area. The Pilot/”Operator” will provide th e location (h e ading and distance) relative to the center of the airspace and request clea ra n c e to “Maneuver” above that location at or below 500 feet AGL. The Pilot/”Operator” will be responsible for “see and avoid” traffic c o nflicts. The Pilot/”Operator” will at all times yield ri ght of way to ANY and ALL m anned flight op erations. All op erations within 2 miles of the primary airport will be pre

- a rranged with that controlling facility. Any and all restrictions placed on the operations will be complied with so that all manned operations can be conducted without negatively impacting flight safety. 14 CFR §91.405 (a); 407 (a) (1); 409 (a) (2); 417 (a) & (b): Maintenance Inspections
The se regulations require that an aircraft operator or owner “shal l have that aircraft inspected as prescribed in
s u b p art E of this part and shall between required inspections, except a s providedi n paragraph (c) of this section, ha ve d iscrepancies repaired as prescribed in part 43 of this chapter... ,” and others shall inspect ormaintain the aircraft in compliance with Part 43.
G i ven that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the Pilot/”Operator” p u rsuant to the flight manual and operating and handbook. An equivalent level of safety will be achieved because these small sUASs are very limited in size and will carry small payload and operate only in limited areas for short periods of time. If mechanical issues arise the sUAS and land immediately and will be operating from no higher than 500 feet AGL. The Pilot/”Operator” will ensure that the sUAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenan ce performed. Moreover, the Pilot/”Operator” is the person most familiar with the aircraft and is best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. An equivalent l evel of safety will be achieved beca use maintenance and inspections will be performed and accordance with the sUAS manufacturer’s manual, as referenced in the Aircraft Operations Manual. As provided in the Operations Manual, the Pilot/”Operator” will ensure that the sUAS is in working order p rior to initiating flight and perform required maintenance needed.

Additional Views and Information Of the applicant, Timothy Gaetano has been involve d in the construction, maintenance, troubleshoo ting, and p i l o ting of RC vehicles for over 25 years. Timothy is also a FAA certified Rotorcraft Private Pilot with a current 2nd class medical and nearly 300 hours total time accrued in Schweizer 300 CBI, Robinson R22/R44, and Bell 206B3. Pursuant to 14 CFR § 11.81, Revolution 6 Media, LLC is seeking the exemption so as to provide unique and high value aerial cinematography services to the public in their best interest

. The capabilities of these sUAS and UAV systems are un-matched by fullscale aircraft and it is my belief t he public has much to gain from these services in way of architectural master planning, still photography, video collection , surveying, mapping, tourism marketing , inspections, etc. T he associated operations are proven to be safe, cost effective and time efficient providing additional benefit to the public. Further, this exemption request cooperates fully within the 333 exemption guidelines and blanket certificate of authorization. Having been involved as a photographer in a manned helicopter accident that burned 10+ acres and nearly took the lives of the pilot and myself during a low level photo mission, the result was the feeling that there had to be a smarter and safer way to execute the mission without seriously risking lives and/or property. sUAS and UAV systems are proving to be it.Summary Pursuant to 14 CFR Part 11, t he following summary is provided for publication in the Federal Register, should it be determined that publication is needed: Applicant seeks an exemption from the following rules: 14 CFR Part 21, subpart H; 14 CFR 45.23(b); 14 C F R 6 1 .113 (a) & (b); 14 CF R 91.7 (a); 14 CFR 91.9 (b) (2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119; 14 CF R 91.121; 14 CFR 91.151 (a); 14 CFR 91.203 (a) & (b); 14 CFR 91.215 (a) & (b); 14 CFR 91.131 (d); 14 C FR 91.405 (a); 14 CFR 407 (a) (1); 14 CFR 409 (a) (2); 14 CFR 417 (a) &( b) to commercially operate a small unmanned vehicle (55 lbs. or less) equipped to conduct aerial photography and cinematography services.
Approval of exemptions allowing commercial operations of sUAs to conduct aerial photography and cinematography services wil l enhance safety by reducing risk. Conventional photography operations, using jet or piston powered aircraft, at extremely low altitudes, often very close to the subject being filmed and in close proximity to people and structures; and present the r isks associated with vehicles that exceed 3,000 lbs., carrying large amounts of jet A or other fuel. In contrast, a sUAS weighing fewer than 55 lbs. and powered by batteries eliminates virtually all of the risk given the reduced mass and lack of combustible fuel carried on board. The sUAS is carried to the location. The sUAS will ca rry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights. The operation of small sUASs, weighing less than 55 lbs., c onducted in the conditions o utlined above, will provide an equivalent level of safety supporting the granting of the exemptions requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations. T hes e lightweight aircraft operate at slow speeds, close to the ground but under 500 feet AGL, and within the limited area and, as a result, are far safer than conventional flight operations conducted with turbine helicopters operating in close proximity to the g round and people. Privacy All flights will occur over private or controlled access property with the property representative or owner’s prior consent and knowledge. Filming will be of people who have also consented to being filmed o r ot herwise have
a g reed to be in the area where filming will take place. All flights will occur in accordance with any state or local laws regarding privacy. Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012—s ize, weight, speed, operating
c ap abilities, proximity to airports and populated areas and operations within visual line of s ight (VLOS) and
n at ional security – provide more than adequate justification for the granting of the requested exemptions allowing commercial operation of applicants sUAS in the aerial photography and cinematography services industry.

Regards, 

# T imothy Gaetano
Revolution 6 Media, LLC 704 Quesnel Drive. Virginia Beach, VA 23454